Related News and Opinion

U.S. 7th Circuit Court of AppealsUnited States of America v. Christopher Eads
12-2464
Criminal. Affirms conviction and 480-month sentence for distributing child pornography, possessing child pornography and
tampering with a witness. Addresses the issues Eads raises on appeal but upholds the decision of the U.S. District Court of
the Southern District of Indiana, Indianapolis Division. Finds the district court did not abuse its discretion in allowing
Eads to represent himself; the conviction for witness tampering was supported by the evidence; a new trial is not warranted
because no new evidence has been discovered; and the discussion of 18 U.S.C. 3553 factors at sentencing was sufficient. Agrees
with Eads that the district court erred in not thoroughly explaining on the record why it allowed images to be shown to the
jury but rules the error is harmless because the additional evidence against him was overwhelming.

United States of America v. Christopher Spears
11-1683
Criminal. Affirms in part, reverses in part and remands for resentencing on convictions of producing false identification
and unlawful possession of false identification. Holds that the federal aggravated identity theft statute USC §1028A’s
reference to “another person” may not be extended to fake ID bearing the true name of the recipient, and therefore
vacates conviction and two-year sentence.